Sharing reasons and whether consumers can limit them
Lead Bank's table lists the reasons it may share personal information, whether it shares for that reason, and whether a consumer can limit the sharing. Lead Bank shares for its everyday business purposes (for example, processing transactions, maintaining accounts, responding to court orders and legal investigations, and reporting to credit bureaus), for its own marketing, and for joint marketing with other financial companies; the table says consumers cannot limit those three categories. It does not share for affiliates' everyday business purposes based on transactions and experiences or creditworthiness, for affiliates to market to you, or for nonaffiliates to market to you; the table says "We don't share" for those four rows.
Details not recorded for this card
Supporting quotations
All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Lead Bank chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
For our everyday business purposes– such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No
For our marketing purposes– to offer our products and services to you Yes No
For joint marketing with other financial companies Yes No
For our affiliates' everyday business purposes– information about your transactions and experiences No We don't share
For our affiliates' everyday business purposes– information about your creditworthiness No We don't share
For our affiliates to market to you No We don't share
For nonaffiliates to market to you No We don't share
Qualifications & exceptions
The answers are read from the table's "Does Lead Bank share?" and "Can you limit this sharing?" columns; the column answers are not repeated in each row quote.
Cross-references
qualified by (model-proposed): Vermont accounts automatically treated as limiting sharing — Vermont accounts are automatically treated as having limited sharing as described above; for joint marketing, only name, contact information, and transaction information are disclosed. This regional rule qualifies the general sharing table.
Sharing & Disclosure · User right or choice
Federal right to limit three sharing categories
Federal law gives consumers the right to limit only three categories of sharing: sharing for affiliates' everyday business purposes about the consumer's creditworthiness, affiliates' use of the consumer's information to market to them, and sharing for nonaffiliates to market to the consumer.
Details not recorded for this card
Supporting quotations
Why can’t I limit all sharing?
Federal law gives you the right to limit only
Sharing for affiliates’ everyday business purposes – information about your creditworthiness
Affiliates from using your information to market to you
No collection or sharing for the limitable purposes; state law may add rights
Lead Bank states that it does not collect or share information for the three purposes for which federal law gives a right to limit. State laws and individual companies may give additional rights to limit sharing.
Details not recorded for this card
Supporting quotations
You should be aware that Lead Bank does not collect or share information for these purposes.
State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.
Qualifications & exceptions
The additional state-law rights are described later in the notice; this card does not summarize them.
Cross-references
qualifies (model-proposed): Federal right to limit three sharing categories — Lead Bank's statement that it does not collect or share information for the three federally limitable purposes qualifies the practical effect of the federal right to limit those categories.
Sharing & Disclosure · Restriction or exception
Vermont accounts automatically treated as limiting sharing
Accounts with a Vermont mailing address are automatically treated as if the account holder had limited sharing as described earlier in the notice. For joint marketing, Lead Bank will disclose only the account holder's name, contact information, and information about transactions.
Details not recorded for this card
Supporting quotations
Accounts with a Vermont mailing address are automatically treated as if they have limited the sharing as described above. For joint marketing, we will only disclose your name, contact information and information about your transactions.
Qualifications & exceptions
This is a Vermont-specific automatic treatment; the notice does not require the account holder to make a request.
Not stated here
The notice does not enumerate the sharing categories covered by the automatic Vermont limitation; it refers to the limitation "as described above."
Cross-references
qualifies (model-proposed): Sharing reasons and whether consumers can limit them — Vermont accounts are automatically treated as having limited sharing as described above; for joint marketing, only name, contact information, and transaction information are disclosed. This regional rule qualifies the general sharing table.
Sharing & Disclosure · Restriction or exception
California accounts automatically treated as limiting nonaffiliate sharing
Accounts with a California mailing address are automatically treated as if the account holder had limited sharing with nonaffiliates as described earlier. California residents seeking additional choices over their data are directed to the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 in the next section.
Details not recorded for this card
Supporting quotations
Accounts with a California mailing address are automatically treated as if they have limited the sharing with nonaffiliates as described above. If you are a California resident and would like to exercise additional choices over your data, please review the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 in the next section.
Qualifications & exceptions
This is a California-specific automatic treatment; the notice does not require the account holder to make a request.
Not stated here
The notice does not enumerate the nonaffiliate sharing covered by the automatic California limitation; it refers to the limitation "as described above."
Sharing & Disclosure · Company practice
No sale, advertising technology, or targeted advertising
Lead Bank says it does not and will not sell consumer personal information in the traditional and colloquial sense of the word sale. It says it does not use advertising technology on its website, which under some State Privacy Laws may be considered a "sale" or "share" of information. In the preceding twelve months, Lead Bank says it has not "sold" or "shared" consumers' personal information as defined under State Privacy Laws, and it does not engage in targeted advertising.
Details not recorded for this card
Supporting quotations
We do not and will not sell consumer personal information in the traditional and colloquial sense of the word sale. We do not use advertising technology on our website, which under some State Privacy Laws may be considered a “sale” or “share” of your information. In the preceding twelve (12) months, we have not “sold” or “shared” consumers’ personal information, as defined under State Privacy Laws. We do not engage in targeted advertising.
Qualifications & exceptions
The notice addresses both the traditional or colloquial sense of "sale" and the statutory definitions of "sold" and "shared" under State Privacy Laws.
Cross-references
contrast (model-proposed): Right to know, access, and data portability — The notice states that Lead Bank has not "sold" or "shared" personal information as defined under State Privacy Laws, while the right-to-know list refers to categories of personal information "disclosed or sold" to each category of third party. The list does not identify any category as sold; the two passages use different framing.